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Children's Alliance response to GraniteCare Medicaid proposal

Why replace a successful Healthy Kids program with an untested scheme in which children will suffer?

January 3, 2005

John A. Stephen
Commissioner
Department of Health and Human Services
129 Pleasant Street
Concord, NH 03301

Dear Commissioner Stephen:

Thank you for the opportunity to provide feedback on your GraniteCare plan. We appreciate your presence at the recent public forums and look forward to an increasingly transparent process.

We have several concerns about GraniteCare' s proposed use of Health Services Accounts (HSA) to provide health coverage for poor children and pregnant women. Our concerns range from the general — whether there is a true need for such drastic change in the delivery of children’s Medicaid and SCHIP services — to more specific concerns about program implementation.

We begin with our overarching concern about the proposed use of HSAs. We recognize that HSAs are a priority of the Bush Administration, but New Hampshire is the wrong place — and poor children and women the wrong populations — for this concept.

Services to children are not a significant driver of Medicaid spending In New Hampshire. While children comprise little more than one-half of New Hampshire's Medicaid recipients, they account for just over 20% of the costs. They are by far the program's lowest-cost recipients.

Before this plan moves forward, The Department should produce data showing where and how children and pregnant women at and over 133% of the federal poverty level are misusing services and wasting Medicaid dollars.

Such data is especially important in light of the proven track record of our existing child health insurance program. New Hampshire's successful Healthy Kids health insurance program was recently praised as a national model by U.S. Senate Majority Leader Bill Frist. Healthy Kids now covers approximately 15,000 Medicaid eligible children and 6,500 SCHIP eligible children. Instead of turning away from this success story, we should build on it — with an increased effort to reach the 17,000 children who remain uninsured. Efforts should focus on outreach and increased provider reimbursement.

Moreover, even if New Hampshire were to consider changes to its Healthy Kids program, it should not adopt an HSA model. HSAs are inappropriate for low-income families with children.

While we applaud proposed incentives for access to preventive care (as well as provider incentives for alcohol and tobacco addiction screening and treatment), we are concerned by the next level of HSA coverage which rewards families who don't spend all of their non-emergency account — thus creating an incentive to forego routine health care for their children. These parents will be faced with the choice of seeking treatment for a child with a possible ear or throat infection or receiving a voucher that might send the child to summer camp.

Parents who are well-informed and well-meaning will make good choices for their children. However, many parents are not informed about health care and a few, sadly, put their own needs ahead of their children's. Poor choices will be made, and children will suffer. We hope you will agree that any incentives built into the plan should reward those who seek timely and appropriate health care.

Finally, we have concerns about the proposed discount drug card. Poor children and pregnant women are the wrong populations for discount drug cards. By allowing consumers who have used all of the funds in their non-emergency accounts to receive drug discount cards to buy prescriptions at participating pharmacies, the plan presents two problems. First, families at or near 133% of poverty don't have the income even to buy discounted drugs. Some will be unable to buy the medicine their children need. Second, families in more-rural areas of New Hampshire may not have access to the discounted medicine if the local pharmacy declines to participate in the program.

Again, thank you for the opportunity to comment. We'd be happy to discuss any of our concerns in more depth.

Sincerely,
Ellen Shemitz
President

Steve Varnum
Public Policy Director

Cc: Gov. John Lynch
Rep. Neal Kurk
Rep. Marshall Lee Quandt
Stephen Norton, DHHS



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